CCBHC Required and Key Personnel

What are the required Key Personnel? The Notice of Funding Opportunity (NOFO) states that “Key personnel are staff members who must be part of the project regardless of whether or not they receive a salary or compensation from the project. These staff members must make a substantial contribution to the execution of the project.” The Key Personnel requirements for the CCBHC program are listed in the NOFO For FY 2022. The program requires two positions, a Project Director at 0.50 FTE and an Evaluator at 0.50 FTE. Please note, these FTE requirements have varied, depending on the CCBHC cohort. For example, for FY 2020, the Evaluator was required to be 1.00 FTE. SAMHSA has since reduced this to 0.50 FTE.

What are the minimum Qualifications for Key Personnel? The NOFO states that Key Personnel (the Project Director and the Evaluator) “require prior approval by SAMHSA after a review of staff credentials and the job descriptions.” Typically, this approval occurs with review of the grant proposal. If there is an issue with the qualification of any key personnel, SAMHSA will ask that it be addressed as a condition in the Notice of Award (NoA). The NOFO further states that, “If an organization is awarded a grant and chooses to move forward with hiring an individual for a Key Personnel position before receiving SAMHSA’s formal approval, this will be done at the organization’s own risk. If SAMHSA’s review of the Key Personnel request results in the proposed individual not being approved or deemed not qualified for the position, the expectation is that the organization must submit a qualified candidate to be placed in the Key Personnel position. SAMHSA will not be liable for any costs incurred or pay for salaries of a Key Personnel that is not approved or deemed not qualified on the grant program.”

While SAMHSA states that Key Personnel must be approved, they offer no specific guidance as to what the qualifications must be, in order to meet approval. Given that, CCBHC Project Directors most often have Master’s Degrees (and often licensure) in Social Work, or Marriage and Family Therapy. Evaluators often have a PhD or some significant experience in the field and/or experience with grant management or data/analytics, etc. We have also seen these roles be filled by individuals with no degree, but with experience that justifies their ability to fulfil the role, and with skills in alignment with the job description.

Are CCBHCs required to have a psychiatrist on staff? Yes. NOFO as required Key Personnel, this requirement is indicated in the CCBHC criteria. There is no minimum FTE, and the position can be filled as an employee or by contract, and in-person or via telehealth. The psychiatrist technically serves as the CCBHC Chief Medical Officer (or equivalent title). If the CCBHC is part of a health center that already has a CMO, the psychiatrist is still necessary.

Is there a salary cap for personnel? When allocating funding for staffing/personnel within the CCBHC budget, salaries should be competitive, but still aligned with the market rate for the service area. SAMHSA limits salaries to $203,700, so the no salary within the CCBHC program can exceed this amount, even if the difference is funded by another source.